Inpatient psychiatric facilities are pushing back at attempts by the CMS to introduce several new quality measures. Dozens of comments made before the June 23 response deadline say the measures hold them accountable for things outside of their control. Meanwhile, psychiatrists and advocates are praising the proposed standards.
The quality measures were outlined in the proposed Inpatient Psychiatric Facilities Prospective Payment System rule released in April.
The proposal introduces new quality metrics that will affect psychiatric facility payments starting in fiscal 2018.
They include determining whether providers attempted to place a patient in a tobacco cessation program after discharge, whether substance-abuse intervention was provided, if there was a screening for metabolic disorders and two other measures related to the transition of medical records.
The measures were largely jeered by behavioral health facilities. For instance, the tobacco measure tracks patients who have used tobacco products and who were referred to counseling and received or refused a prescription for cessation medication upon discharge.
“The proposed tobacco use treatment measures were not created for psychiatric hospital settings and do not address the quality of psychiatric care,” Darla York, director of Risk Management at the Arkansas-based Springwoods Behavioral Health Hospital, said in a comment. “Specifically, (part of the measure) penalizes the provider for a patient's refusal to receive treatment, and thus is not an indicator of provider quality but of patient cooperation. It is our opinion that public reporting should focus on measures that are directly related to reasons that patients seek or require inpatient psychiatric services.”
A quality measure tied to alcohol-use intervention also raised red flags. The measure asks providers to evaluate whether patients who screen positive for unhealthy alcohol use receive or refuse a brief intervention during the hospital stay. Psychiatric facilities again argue that the measure was created for general hospitals and has nothing to do with addressing the quality of psychiatric care. Like the tobacco measure, the quality metric penalizes the provider for a patient's refusal to receive treatment.
“Public reporting of tangential population health measures detract from provider abilities to focus on optimal care and may be misleading as to the quality of psychiatric care provided,” said Greg LaFrancois, CEO of Prairie St. John's, a behavioral health facility in North Dakota.
Others were thrilled with the quality measure recommendations. “Given the prevalence of tobacco use among persons with mental illness and the detrimental effects of tobacco use on overall health, the (American Psychiatric Association) is in full agreement that clinicians should provide tobacco use screening and offer treatment,” Dr. Saul Levin, CEO of the trade group, said in a comment.
"While inpatient psychiatric facilities may not be primarily established to provide substance use treatment, the lack of such treatment during periods of hospitalization impedes the effectiveness of psychiatric treatment and the likelihood of recovery,” he added.
The National Alliance on Mental Illness also supports the quality measures, including the one related to alcohol use.
“While inpatient psychiatric facilities may not be primarily established to provide substance use treatment, the lack of such treatment during periods of hospitalization impedes the effectiveness of psychiatric treatment and the likelihood of recovery,” NAMI said in a comment letter.
The agency received more than 70 comments in total. The CMS will release a finalized rule this summer or early fall, and it will kick in Oct. 1.
There are more than 1,600 inpatient psychiatric facilities in the U.S., and they treat about 300,000 Medicare beneficiaries each year, costing roughly $4 billion annually.
In the same rule as the new quality standards, the CMS also proposed that inpatient psychiatric facilities get a 1.6% rate increase from Medicare in fiscal 2016. That means Medicare would spend $80 million more on psychiatric facilities in fiscal 2016 than in fiscal 2015. However, the increase is smaller than the 2.5% raise they received for the current year.